Title
Supreme Court
Comglasco Corp. vs. Santos Car Check Center Corp.
Case
G.R. No. 202989
Decision Date
Mar 25, 2015
Santos leased a property to Comglasco for five years; Comglasco pre-terminated, refused to pay rent, and was sued. Courts ruled in Santos' favor, affirming breach of contract and awarding damages, with reduced attorney’s fees.

Case Digest (G.R. No. 202989)
Expanded Legal Reasoning Model

Facts:

  • Lease Agreement
    • On August 16, 2000, Santos Car Check Center Corporation (Santos), owner of a showroom at 75 Delgado Street, Iloilo City, leased the space to Comglasco Corporation (Comglasco) for five years.
    • Rental schedule: ₱60,000/month (1st year), ₱66,000/month (2nd year), ₱72,600/month (3rd–5th years).
  • Pre-termination and Default
    • On October 4, 2001, Comglasco sent a letter notifying Santos of its intention to pre-terminate the lease effective December 1, 2001. Santos refused, insisting on the five-year term.
    • Comglasco vacated the premises on January 15, 2002, ceased paying rent, and ignored multiple demand letters, including a final demand on September 15, 2003.
  • Trial and Appeals
    • Santos filed suit for breach of contract on October 20, 2003; summons served January 21, 2004. Comglasco’s motion to dismiss for improper service was denied; it filed its Answer on June 28, 2004.
    • Santos moved for judgment on the pleadings under Rule 34, §1; the RTC granted it and, on August 18, 2004, ordered Comglasco to pay unpaid rentals (Jan 16, 2002–Aug 15, 2003) totaling ₱1,333,200 plus 12% interest, plus ₱200,000 attorney’s fees, ₱50,000 litigation expenses, ₱400,000 exemplary damages, and costs.
    • The Court of Appeals (CA), in a Decision dated August 10, 2011, affirmed the RTC’s decision but reduced attorney’s fees to ₱100,000 and deleted litigation expenses and exemplary damages.
    • Comglasco petitioned the Supreme Court raising issues on judgment on the pleadings, material issues in its Answer, summary judgment vs. judgment on pleadings, credit for advance rental/deposit, and basis for attorney’s fees.

Issues:

  • Whether judgment on the pleadings was properly invoked by the trial court.
  • Whether Comglasco’s Answer raised material issues requiring evidence.
  • Whether summary judgment rather than judgment on the pleadings was the proper remedy.
  • Whether Comglasco’s advance rental and deposit (₱309,000) should be credited against Santos’s award.
  • Whether attorney’s fees may be granted without proof and legal stipulation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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